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  • Chair: Laura Gould, Reed Smith LLP, London, United Kingdom US Activities of Foreigners & Tax Treaties Chair: Summer A. LePree, Bilzin Sumberg Baena Price & Axelrod LLP, Miami, FL Revisiting the BEAT. Following up on the 2018 proposed regulations, Treasury released both final and proposed regulations addressing the BEAT. This panel will focus on some of the changes made by Treasury from the 2018 proposed regulations to the final regulations, including rules relating to the treatment of certain corporate nonrecognition transactions, the treatment of aggregate group members with different tax years and the treatment of built-in loss property in certain transactions. Additionally, this panel will highlight some of the provisions Treasury chose not to adopt in the final regulations. Finally, the panel will provide an overview of the newly proposed regulations that include rules relating to aggregate groups, partnerships and an election to waive deductions. Panelists: Amie Colwell Breslow, Jones Day, Washington, DC; Joseph Calianno, BDO USA LLP, Washington, DC; Lucas Giardelli, Mayer Brown LLP, New York, NY; David Peter Merkle, IRS Office of Associate Chief Counsel (International), Washington, DC (Invited); Douglas Poms, International Tax Counsel, Department of Treasury, Washington, DC (Invited) Opening Pandora’s Box: IP Tax Incentives in the US & Europe. Many OECD countries have adopted patent box regimes or other rules intended to incentivize corporations to hold intellectual property within their jurisdiction, some of which have been the subject of recent reform following the BEPS Reports, and in particular Action 5. Although the 2017 Tax Act did not include a traditional patent box regime, it did add the new foreign-derived intangible income (FDII) rules, which, in connection with other rules added by the 2017 Tax Act, are generally intended to encourage domestic corporations to hold intellectual property in the United States. Using case studies, this panel of experts will explore the differences and similarities between FDII and patent box and similar rules in the UK and certain EU-member countries, as well as the interaction of the FDII rules with certain domestic rules in those countries that can impact IP structuring decisions for multinationals. The panel will also discuss potential international trade reaction to the FDII rules, including from an EU perspective. Moderator: Barbara Rasch, KPMG LLP, Los Angeles, CA Panelists: Sandy Radmanesh, German Tax Attaché, German Embassy, Washington, DC; James Somerville, A&L Goodbody, Dublin, Ireland; Natalie Repyens, Loyens & Loeff CVBA, Brussels, Belgium; Robert Gaut, Proskauer Rose (UK) LLP, London, UK; Romain Tiffon, Atoz Tax Advisers, Luxembourg Foreign Lawyers Forum – Anti-Hybrid Rules: The New World. With the EU setting a January 1, 2020 deadline for the introduction of anti-hybrid rules under ATAD2 and the implementation of anti-hybrid rules under the TCJA, this timely panel will discuss the potential application of anti-hybrid rules. The panel will provide updates on the implementation of the ATAD 2 rules in key EU member states, an update on the application of the US anti-hybrid rules following the publication of the proposed regulations just over a year ago and the UK’s existing and wide-reaching legislation. Through case studies, this expert panel will explore the differences, similarities and interaction between these various rules and highlight traps for the unwary in a sample of typical cross-border structures used by multinationals and fund structures. Moderator: Brian Krause, Skadden Arps Slate Meagher & Flom, New York, NY Panelists: Robert Gaut, Proskauer Rose (UK) LLP, London, UK; David Kilty, Arthur Cox, Dublin, Ireland; Kévin Emeraux, Loyens & Loeff (Luxembourg), New York, NY; Shane M. McCarrick, Attorney-Advisor, IRS Office of Associate Chief Counsel (International), Washington, DC
  • Chair: Heesun Grace Kim, Grant Thornton LLP, Washington, DC Hot Topics. This panel will discuss recent developments in the area of partnership taxation, including legislation, regulations, administrative guidance and noteworthy cases. Moderator: Tom West, KPMG LLP, Washington, DC Panelists: Bryan Rimmke, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited) How Far Will You Carry Your Client? Section 1061 As It Stands Today. This panel will discuss section 1061 (the so-called “carried interest” provision) enacted under the TJCA. The panel will outline the technical aspects of section 1061 and highlight some of its ambiguities. The panel will further discuss current developments that have occurred since its enactment—including specific guidance recommendations made by the Partnership Committee. The panel will also discuss what the future proposed regulations under section 1061 may provide. Moderator: Todd Golub, EY, Chicago, IL Panelists: Kara Altman, IRS Office of Chief Counsel (Passthroughs & Special Industries), Washington, DC (Invited); Audrey Ellis, PwC, Washington, DC; Morgan Klinzing, Pepper Hamilton LLP, Philadelphia, PA; Mike Scaramella, Deloitte LLP, Chicago, IL Tax Issues of Dry Partnerships. This panel will address tax issues that arise when a partnership owns stock in a corporation as its sole or primary asset, including section 704(b) allocation issues (e.g., with regard to preferred distribution rights), issuance of compensatory partnership interests to employees of the corporation, and the application of section 704(c). Moderator: Eric Sloan, Gibson Dunn & Crutcher LLP, New York, NY Panelists: Josh Brady, Grant Thornton LLP, Washington, DC; Erin Cleary, Debevoise & Plimpton LLP, New York, NY
  • Sponsored by: Young Lawyers Forum and Diversity A Conversation with… An in-depth discussion with Chief Judge Maurice B. Foley of the US Tax Court, one of the Tax Section’s most distinguished members, detailing his practice, history and the latest developments in tax law. Nuts and Bolts: Introduction to Ethical Considerations for Young Attorneys. This panel will discuss the ethical issues that frequently arise when representing a client before the IRS. This panel will focus on the rules and guidance, including Circular 230 and the ABA Model Rules, that young attorneys should consult when faced with an ethical conundrum. Moderator: Anne Wurtzebach, DLA Piper, New York, NY Panelists: Hon. Ronald L. Buch, US Tax Court, Washington DC (Invited); Joshua Wu, Deputy Assistant Attorney General (Policy and Planning), Department of Justice, Tax Division, Washington, DC; Brianne DeSellier, Crowe LLP, Fort Lauderdale, FL; James Steele, Morgan, Lewis & Bockius LLP, Washington, DC Workin’ On It: Understanding Employment Tax. Employment tax compliance has become an enforcement priority for the IRS and the result has been more civil examinations and criminal investigations. This panel will survey the common issues in the employment arena and approaches in defending an employment tax controversy. The panelists will discuss Section 530 relief, voluntary compliance options, the eggshell audit and the criminal referral process. Moderator: Anson Asbury, Asbury Law Firm, Decatur, GA Panelists: Lu-Ann Dominguez, Gunster, Ft. Lauderdale, FL; Brian Gardner, Taylor English, Atlanta, GA; Marissa Lenius, IRS Senior Attorney, TEGE Division Counsel, Jacksonville, FL Getting to the Truth: Fundamentals of Discovery & Public Records for SALT Lawyers. This panel will delve into a crucial reality for tax lawyers—the exchange of information between taxpayer and tax authority. State and local tax (“SALT”) lawyers encounter this in various contexts: tax audits, discovery during litigation, and requests for public records. The panel will discuss the fundamentals of obtaining information, tips to prevent and resolve disputes about the exchange of information, and protections for confidential information. The panelists represent diverse perspectives of SALT lawyers in private practice and government practice, including a tax appeal hearing officer. Moderator: Michelle DeLappe, Foster Garvey PC, Seattle, WA Panelists: Vincent Kan, Hearing Officer, Board of Appeals at Illinois Department of Revenue, Chicago, IL; Andrea Muse, Legal Reporter, Tax Analysts, Washington, DC; Jennifer Pusch, Fredrikson & Byron PA, Minneapolis, MN; Harriet A. Wessel, Mondrik & Associates, Austin, TX Co-Sponsored by: Court Procedure & Practice
  • Chair: Stephen Breitstone, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY Real Estate Chair: Ossie Borosh, KPMG LLP, Washington, DC Nuts and Bolts of Opportunity Zones and Qualified Opportunity Funds. This panel will cover the law, regulations, and the practical implementation thereof for Opportunity Zones (“OZs”) and Qualified Opportunity Funds (“QOFs”). It is the perfect panel both for those unfamiliar with OZs and QOFs, as well as those who are familiar with the law and regulations but have not practiced in the area. Additionally, seasoned practitioners will benefit from a discussion of the final regulations with respect to OZs. Moderator: Matthew Rappaport, Falcon Rappaport & Berkman PLLC, Rockville Center, NY Panelists: Richard Blumenreich, KPMG LLP, Washington, DC; Alan S. Lederman, Gunster, Fort Lauderdale, FL; Leila Vaughan, Royer Cooper Cohen Braunfeld LLC, Conshohocken, PA; Julie Hanlon-Bolton, Special Counsel, IRS Associate Chief Counsel (Income Tax & Accounting), Washington, DC Common and Complex Case Studies and Real-World Issues with Opportunity Zones and Qualified Opportunity Funds. The second hour of this program will focus on issues related to funds, raising capital, and dispositions. This discussion will be valuable both for practitioners just learning about OZs and QOFs and for seasoned professionals, as it will incorporate a discussion of transaction structures. Additionally, there will be a further discussion of the final regulations covering OZs. Moderator: Tom West, KPMG LLP, Washington, DC Panelists: Richard Blumenreich, KPMG LLP, Washington, DC; Mark Wilensky, Meltzer Lippe Goldstein & Breitstone LLP, Mineola, NY; Julie Hanlon-Bolton, Special Counsel, IRS Associate Chief Counsel (Income Tax & Accounting), Washington, DC
  • Chair: Sam Weiler, EY, Columbus, OH Current Developments and Update on Pending Guidance. This panel will cover the important recent developments in the areas of capital recovery and leasing. Moderator: Jessica Hawn, Andersen, Chicago, IL Panelists: Kathy Reed, Branch Chief, Branch 7, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Wendy Friese, Tax Policy Advisor, Department of Treasury, Washington, DC (Invited); Andrew Eisinger, Crowe, Atlanta, GA Transactions and Bonus Depreciation. This panel will discuss various corporate and partnership transactions and their impact on the availability of bonus depreciation under section 168(k). Moderator: Nicole Field, EY, Washington, DC Panelists: Kathy Reed, Branch Chief, Branch 7, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Wendy Friese, Tax Policy Advisor, Department of Treasury, Washington, DC (Invited); Mark Weiss, Branch Chief, Branch 2, Office of Chief Counsel – Corporate, IRS, Washington, DC (Invited); Bryan Rimmke, Attorney-Advisor, Department of Treasury, Washington, DC (Invited); Jason Dexter, KPMG, Washington, DC; Richard Nugent, Jones Day, New York, NY Implementing the Bonus Depreciation Regulations. This panel will be focused on the procedural aspects of implementing the final and re-proposed bonus depreciation regulations under section 168(k), with a specific focus on the issues and opportunities raised by the recent guidance and the actions that taxpayers can take to align their current and prior year return positions with the regulations. Moderator: Jane Rohrs, Deloitte, Washington, DC Panelists: Kathy Reed, Branch Chief, Branch 7, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Wendy Friese, Tax Policy Advisor, Department of Treasury, Washington, DC (Invited); Jaime Park, Attorney, Office of Chief Counsel – Income Tax & Accounting, IRS, Washington, DC (Invited); Andrea Mouw, Eide Bailley, Minneapolis, MN
  • Chair: Carolyn (Morey) O. Ward, Ropes & Gray LLP, Washington, DC News from the IRS and Treasury. Representatives from the IRS and Treasury Department will discuss topics of current interest to exempt organizations practitioners. Moderator: Celia Roady, Morgan Lewis, Washington, DC (Invited) Panelists: Victoria A. Judson, Associate Chief Counsel, IRS Office of Chief Counsel (TEGE), Washington, DC (Invited); Janine Cook, Deputy Associate Chief Counsel, IRS Office of Chief Counsel (TEGE), Washington, DC (Invited); Elinor C. Ramey, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited) Up in Smoke: Marijuana, Tax-Exempt Organizations and the Criminality Doctrine. What can tax-exempt organizations do when they are caught between state laws legalizing marijuana sale and use and federal laws that prohibit such activities? Don’t worry, be happy may not be the right answer. Moderator: James P. Joseph, Arnold & Porter, Washington, DC Panelists: Professor Philip Hackney, University of Pittsburgh School of Law, Pittsburgh, PA; Evalina Norwinski, Arnold & Porter, Washington, DC A “20/20” Look at the 2017 Tax Act. This panel will discuss any newly released guidance under sections 512(a)(6) and 4960 impacting tax exempt organizations. Moderator: Gil Ghatan, Ropes & Gray LLP, Washington, DC Panelists: Victoria A. Judson, Associate Chief Counsel (EEE), IRS Office of Chief Counsel, Washington, DC (Invited); Janine Cook, Deputy Associate Chief Counsel (EEE), IRS Office of Chief Counsel, Washington, DC (Invited); Elinor C. Ramey, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited); Chelsea Rubin, Morgan Lewis, Washington, DC; Robert A. Wexler, Adler & Colvin, San Francisco, CA Exempt Organizations Committee Luncheon Rising Seas: Facts v. Fiction Speaker: John Englander, Oceanographer, Author of High Tide On Main Street: Rising Sea Level and the Coming Coastal Crisis Section 501(c)(3) and Hate Speech. While the Internal Revenue Code is silent on standards for speech, the Treasury Department and the IRS have endeavored to craft guidance that comports with the First Amendment while minimizing the use of tax-exempt organizations as vehicles for the promulgation of hate speech. This panel will look at current issues relating to 501(c)(3) status and non-educational speech, particularly speech that constitutes hate speech. Moderator: Marcus Owens, Loeb & Loeb LLP, Washington, DC Panelists: Professor Frances R. Hill, University of Miami School of Law, Coral Gables, FL; Ryan Oberly, Wagenmaker & Oberly, Charleston, SC Controversial Gifts: Solutions Through Policy and/or Agreement. The panelists will discuss tax and other legal considerations in structuring, negotiating, and accepting charitable gifts that involve donor naming and/or donor-imposed restrictions on the use of the gift, with a focus on finding practical ways to avoid or minimize controversy and disputes with donors through the use of institutional policies, contract clauses, and internal training and protocols. Moderator: John Sare, Patterson Belknap Webb & Tyler LLP, New York, NY Panelists: Deborah G. Marx, Tulane University, New Orleans, LA; Donna J. Snyder, University of Michigan, Ann Arbor, MI
  • Chair: Martha N. Steinman, Hogan Lovells US LLP, New York, NY The SECURE Act. As the most extensive retirement legislation since 2006, the recently enacted SECURE Act, much of it effective January 1, 2020, raises important planning and compliance issues and opportunities for participants, plan sponsors, practitioners, service providers, savers, and regulators. This session, presented by a Committee member involved in developing and negotiating a number of the new provisions, will address the major SECURE Act provisions and the issues they raise relating to lifetime income; open MEPs; nondiscrimination relief for frozen and closed plans; and changes affecting timing of plan adoption, 401(k) auto enrollment safe harbor, adoption of 401(k) safe harbor status, RMD rules, coverage of part-time employees, tax credits for new plan startups and for auto enrollment, IRAs, etc. Moderator: Martha N. Steinman, Hogan Lovells US LLP, New York, NY Panelist: J. Mark Iwry, Brookings Institution, Washington, DC & Wharton School, Univ. of Pennsylvania, Philadelphia, PA What’s in a Name? Association Health Plans and Association Retirement Plans: These Cousins Couldn’t Be More Different. This panel of experts will dive into the fray and analyze the battle lines drawn over association health plans and association retirement plans as a microcosm of the battle between red states and blue states. Find out whether proponents of association health plans oppose association retirement plans (and vice versa), and learn the projected location of the upcoming battlefields. Join us as we provide an up-to-the-minute update on association health plan and association retirement plan litigation, regulation and guidance focusing on the issues that all plans, employers, insurance carriers, participants, and service providers need to know now. Moderator: Erin M. Sweeney, Miller & Chevalier Chartered, Washington, DC Panelists: Christopher E. Condeluci, CC Law & Policy, Washington, DC; Joel R. Hurt, Feinstein Doyle Payne & Kravec LLC, Pittsburgh, PA; Anthony F. Shelley, Miller & Chevalier Chartered, Washington, DC Department of Labor, Employee Benefits Security Administration and Pension Benefit Guaranty Corporation Hot Topics. Representatives from the Department of Labor and Pension Benefit Guaranty Corporation will provide updates on the latest guidance and developments affecting employee plans. Moderator: Harold Ashner, Keightley & Ashner LLP, Washington, DC Panelists: Gregory Katz, Attorney, Regulatory Affairs Division, Office of General Counsel, Pension Benefit Guaranty Corporation, Washington, DC; Kimberly Neureiter, Attorney, Bankruptcy, Transactions and Terminations Department, Office of General Counsel, Pension Benefit Guaranty Corporation, Washington, DC; Constance Donovan, Participant and Plan Sponsor Advocate, Pension Benefit Guaranty Corporation, Washington, DC; Camille Castro, Senior Associate, Participant and Plan Sponsor Advocate, Pension Benefit Guaranty Corporation, Washington, DC Department of Treasury / IRS Hot Topics. Representatives from the Department of Treasury and the IRS will provide updates on the latest guidance and developments affecting employee plans. Moderator: Bret Hamlin, Hill Ward Henderson, Tampa, FL Panelists: Carol Weiser, Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC; Victoria Judson, Associate Chief Counsel, Employee Benefits, Exempt Organizations, and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Stephen Tackney, Deputy Associate Chief Counsel (Employee Benefits), Employee Benefits, Exempt Organizations, and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Kevin Knopf, Senior Technician Reviewer, Health and Welfare Branch, Employee Benefits, Exempt Organizations and Employment Taxes, IRS Office of Chief Counsel, Washington, DC
  • Chair: Mark O. Norell, Ballard Spahr LLP, New York, NY Legislative, Treasury and Internal Revenue Service Update. This panel will discuss: (i) an update on the “new” Office of Tax Exempt Bonds; (ii) the status of the Final Reissuance Regulations; (iii) the proposed regulations addressing reference rates other than Interbank Offered Rates; (iv) Indian River County v. U.S. Department of Transportation (Dec. 20, 2019), (v) the Internal Revenue Service Business Plan items for 2019-2020; and (vi) the Internal Revenue Service Audit Plan (Fiscal Year 2020 Compliance Program). Moderator: Mark O. Norell, Ballard Spahr LLP, New York, NY Panelists: Adam C. Harden, Norton Rose Fulbright US LLP, San Antonio, TX; Michela Daliana, Hawkins Delafield & Wood LLP, New York, NY Repeal of Advance Refundings and the Rise of Taxable Municipal Bonds. Given the increasing popularity of taxable municipal bonds, this panel will provide a discussion on issues that arise with regard to refunding taxable bonds with tax-exempt bonds and issuing taxable bonds to refund tax-exempt bonds, with issues to include (a) reimbursement considerations related to taxable new money debt, (b) allocations related to taxable debt used to finance projects eligible for tax-exempt financings and projects ineligible for tax-exempt financings, (c) refunding Build America Bonds, (d) universal cap considerations, and (d) original issue discount considerations for taxable bonds. Moderator: Marybeth Orsini, Ballard Spahr LLP, Baltimore, MD Panelists: Chas Cardall, Orrick Herrington & Sutcliffe LLP, San Francisco, CA; Neil Kaplan, Hawkins Delafield & Wood LLP, New York, NY; Mark O. Norell, Ballard Spahr LLP, New York, NY What Does Cinderella Look Like? This panel will focus on one or more Cinderella structures, including a direct lending transaction that starts with a taxable rate and either grants an option to the issuer to convert to a tax-exempt rate or requires the parties to agree in the future to convert. Moderator: David J. Cholst, Chapman and Cutler LLP, Chicago, IL Panelists: Mark O. Norell, Ballard Spahr LLP, New York, NY; Chas Cardall, Orrick Herrington & Sutcliffe LLP, San Francisco, CA Tax Exempt Financings and Partnerships. This panel will consist of a discussion relating to financing projects owned or otherwise used by partnerships in which at least one partner is a for profit entity. It will compare and contrast how the regulations under sections 141 and 145 work when bond-financed assets are contributed to a partnership or acquired by a partnership and when improvements to partnership assets are financed. The interaction between the partnership-specific rules and the more general rules about qualified equity and eligible mixed-use projects will be explored in detail. Moderator: Chas Cardall, Orrick Herrington & Sutcliffe LLP, San Francisco, CA Panelists: Andrea Ball, Orrick Herrington & Sutcliffe LLP, Washington, DC; Michela Daliana, Hawkins Delafield & Wood LLP, New York, NY
  • Chair: William Alexander, Skadden Arps Slate Meagher & Flom LLP, Washington, DC Current Developments in Corporate Taxation. This panel will discuss the latest developments in corporate taxation, including a discussion of the treatment of various corporate transactions under the BEAT, in the context of qualified opportunity funds and section 355(e). Moderator: Angela R. Russo, KPMG LLP, San Francisco, CA Panelists: Colin D. Campbell, Jr., Department of Treasury, Washington, DC (Invited); David H. Saltzman, Ropes & Gray LLP, Boston, MA; Lisa M. Zarlenga, Steptoe & Johnson LLP, Washington, DC Section 367(b) in a Post-TCJA World. This panel will discuss the continued relevance of section 367(b) post-TCJA. The speakers will discuss how changes made by the TCJA affect the policy considerations of section 367(b), how the changes to the repatriation and basis importation rules might affect the principles underlying Treas. Reg. 1.367(b)-3 and the triangular reorganization provisions, the heightened importance of attribute carryover and allocation under Treas. Reg. 1.367(b)-7 and Prop. Treas. Reg. 1.367(b)-8, and other issues relating to the changed incentives and disincentives in light of TCJA’s overhaul of the international tax rules. Moderator: Scott M. Levine, Jones Day, Washington, DC Panelists: Joshua Rutland, EY, Washington, DC; Gretchen Sierra, Deloitte, Washington, DC; Laura Williams, Branch Chief, Associate Chief Counsel (International), Branch 4, IRS, Washington, DC (Invited); Brenda Zent, Special Advisor on International Taxation, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)
  • Chair: Martha N. Steinman, Hogan Lovells US LLP, New York, NY The Future of Benefits – The SECURE Act. Join us for a discussion about the SECURE Act and other retirement plan provisions passed at the end of 2019, including how they may impact employee benefit planning. Moderator: Elena Kaplan, Jones Day, Atlanta, GA Panelists: Mindi M. Johnson, Foster Swift Collins & Smith PC, Grand Rapids, MI; Veena K. Murthy, Crowe LLP, Washington, DC Hot Topics in Executive Compensation – 162(m). This session will address the impact of the proposed regulations issued under section 162(m) and the recent ABA Tax Section comment letter to the IRS regarding potential dual employee status for entities taxable us partnerships. Moderator: Andrew C. Liazos, McDermott Will & Emery LLP, Boston, MA Panelists: Ilya Enkishev, Attorney, Executive Compensation Branch, Associate Chief Counsel (Employee Benefits), Employee Benefits, Exempt Organizations, and Employment Taxes, Office of Chief Counsel, IRS, Washington, DC; Helen Morrison, EY, Washington, DC; Robert Neis, Eversheds Sutherland, Washington, DC; Stephen Tackney, Deputy Associate Chief Counsel (Employee Benefits), Tax Exempt and Government Entities, Office of Chief Counsel, IRS, Washington, DC; Carol Weiser, Benefits Tax Counsel, Office of Benefits Tax Counsel, Department of Treasury, Washington, DC; Amber Salotto, Attorney-Advisor, Department of Treasury, Washington, DC The Evolving Practice of Employee Benefits Law and Related Ethics Issues. This panel will discuss ethics issues that have arisen under the ABA Model Rules and Circular 230 with the changes in how employee benefits law is practiced in various firm, corporate and government settings. Moderator: Donald E. Wellington, Reed Smith LLP, Los Angeles, CA Panelists: Rosina Barker, Morgan Lewis & Bockius LLP, Washington, DC; Amy Null, WilmerHale, Boston, MA; Robert Toth, Law Offices of Robert J. Toth, Ft. Wayne, IN; Sarah Touzalin, Seyfarth Shaw LLP, Chicago, IL
  • Chair: Mary I. Slonina, PwC, Washington, DC Important Developments. This panel will discuss current developments and topics of immediate interest in tax administrative practice. Panel will focus on recent legislative efforts impacting tax law and the IRS, Treasury and IRS guidance, court decisions, ongoing litigation and other items germane to tax administration. Moderator: Antoinette Ellison, Jones Day, Atlanta, GA Panelists: Chuck Hodges, Jones Day, Atlanta, GA; Kathryn A. Zuba, Associate Chief Counsel, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC Practical Privilege Issues. Would your client rather give their documents to the IRS, the New York Times, or both? This panel will discuss the rules protecting communications from disclosure, using real-world examples. We will also touch on hot topics and best practices. Panelists: Paul Butler, Kostelanetz & Fink LLP, Washington, DC; Abbey Garber, Thompson & Knight, Dallas, TX; Peter K. Reilly, Special Counsel, IRS Office of Associate Chief Counsel (Procedure and Administration), Washington, DC; Melissa Wiley, Ernst & Young LLP, Washington, DC Preparing For and Managing an IRS Examination with Virtual Currency Issues. This panel will discuss IRS efforts in encouraging and reviewing taxpayer reporting of virtual currency transactions, including recent efforts in issuing “educational letters” to taxpayers and the Virtual Currency Compliance Campaign. The panel will also discuss best practices to prepare for and manage an IRS examination of virtual currency issues. Moderator: Daniel Strickland, Eversheds Sutherland, Washington, DC Panelists: Rochelle Hodes, Crowe LLP, Washington, DC; Richard Sapinski, Sills Cummis & Gross, Newark, NJ; Zhanna Ziering, Caplin & Drysdale, New York, NY